Minnesota Department of Transportation — Hazardous Materials Safety Interpretation

Page 1• of Transportation US. Department Washington, D.C. 400 Seventh Streel, S.W 20590 JAN | 6 1998 Mr. Michael Ritchie Office of Motor Carrier Services Minnesota Department of Transportation 1110 Centre Pointe Curve Mendota Heights, MN 55118 Dear Mr. Ritchie: ! This is in response to your letter dated August 7, 1997, requesting clarification of the placarding requirements under the Hazardous Materials Regulations (HMR; 49 CFR Parts : 1/1-180). Your questions are paraphrased and answered as follows: Q1. A truck in interstate commerce is carrying 800 pounds of "Chlorine, 2.3, UN1017", a poisonous gas with subsidiary hazard Class 8 (corrosive), in non-bulk cylinders with no other hazardous material on board. What placard(s) are required? A1. Both POISON GAS and CORROSIVE placards are required, as prescribed by § 172.505(a). Q2. A truck in interstate commerce carries 1,500 pounds of "Chlorine, 2.3, UN1017," a poisonous gas with subsidiary hazard Class 8 (corrosive), in non-bulk cylinders with no other hazardous material on board. What placard(s) are required? Since the load hazard? exceeds 454 kg. has the placarding requirement changed because of the subsidiary A2. The answer is the same as in A1. The fact that the load exceeds 454 kg does not alter the placarding requirement. Q3. A truck in interstate commerce carries, in non-bulk packagings, 800 pounds of "Bromine, 8, UN1744, PG I," a poisonous-by-inhalation Hazard Zone A material that is corrosive and has a subsidiary hazard class of Division 6.1 (poisonous material). What placards) are required? :#

Page 2.. A3. Both POISON INHALATION HAZARD and CORROSIVE placards are required, as prescribed by § 172.505(a). : I hope this information is helpful. Should you have further questions, please contact us. Sincerely, Hatre z mithe 28 Hattie L. Mitchell, Chief Exemptions and Regulations Termination Office of Hazardous Materials Standards .... 2#

Page 3MINNESOTA Minnesota Department of Transportation Bette Ван ок трав. Office of Motor Carrier Services GNB Building, MS420 File 172.504 1110 Centre Pointe Curve Mendota Heights, MN 55118 Sc: 270,274 Fax: 612/405-6082 612/405-6060 TDD: 612/405-6072 August 7, 1997 • Thomas G. Allen Deputy Director Office of Hazardous Materials Standards US DOT/ RSPA 400 Seventh St. S.W. Washington, D.C. 20590 Re: Request for interpretation of placarding regulations. 49 CFR 172.504 requires placarding of transport vehicles and freight containers carrying hazardous materials. Paragraph ( c) of that section gives the exceptions from placarding for loads of less than 454 kg.. Paragraph ( c) also states that the "454 kg. exception" does not apply to •bulk packagings or hazardous materials subject to section 172.505. My office has received complaints of inconsistent interpretations and enforcement of the placarding requirements for materials that are designated as poison inhalation hazards by the hazardous materials table and section 172.203(m). The complainant is a Minnesota based interstate carrier of hazardous materials, who reports they have been inspected and found with no defects in one state, and then crossed a state line with the same exact load and placards and have been cited for improper placarding. They have requested immediate assistance and written claritication of the placarding requirements for hazardous materials with primary or subsidiary PIF classifications. They have provided the following examples: 1. A truck in interstate commerce is carrying 800 pounds of "Chlorine, 2.3, UN1017" in non-bulk cylinders. Cblorine has a Class 8 subsidiary hazard. No other hazmat is on the truck. What placard(s) are required? 2. A truck in interstate commerce carries 1500 pounds of "Chlorine, 2.3, UN1017" in non- 2?1 bulk cylinders. No other hazmat is carried. What placard(s) are required? Since the load exceeds 454 kg. has the placarding requirement changed because of the subsidiary hazard? 3. A truck in interstate commerce carries 800 pounds of "Bromine, 8, UN1744, PG I" in non-bulk packaging. Bromine has a subsidiary hazard of Division 6.1, and is designated a PIH material in hazard zone A by Special provision 1 on the hazardous materials table. No other hazmat is carried. What placard(s) are required? An equal opportunity employer#

Page 4The carrier reports they transport Chlorine frequently, and they will comply with all placarding requirements. They intend to carry a copy of the RSPA interpretation letter in their trucks. Thank you for your assistance in this matter. Please send your response to me at the address below, or fax it to me at (612) 405-6082. If you have any questions, my direct telephone is (612) 405-6120. Yours truly, MalalRitter Michael Ritchie Hazardous Material Specialist Minnesota Department of Transportation Office of Motor Carrier Services 1110 Centre Pointe Curve Mendota Heights, MN 55118#

Page 5MINNESOTA Minnesota Department of Transportation Office of Motor Carrier Services ST_A Mail Stop 420 Mendota Heights, MN 55118 1110 Centre Pointe Curve 0o AUG-8'37I U.S.P MIN 20042 Thomas G. Allen Office of Hazardous Materials Standards US DOT/RSPA 400 Seventh St. S.W. Wasbington, D.C. 20590 →.. . AUTO 2859g#